RE: First Impression of Policy Goals and Implementation

[Barry Zalph <bzalph@co.jefferson.ky.us>]

I (Barry Zalph) work for the local air pollution control agency in Louisville, KY. I have training in mediation and public policy facilitation as well as three engineering degrees. My participation in public involvement processes to date has mainly involved transportation infrastructure projects. I have not yet had any involvement in a PIP involving EPA.

Like Sheila Foster, I find the draft public involvement policy laudably broad and well-founded. Somebody at EPA either paid close attention to public input in developing this draft or did a whole lot of book learning. The draft eventually answered nearly all of the concerns that occurred to me.

Several people have commented on the distinction between public input (i.e., the public provides opinions and information that EPA factors into EPA's decisions) and collaboration (in which EPA and stakeholders jointly explore an issue, develop alternatives, evaluate alternatives, and choose one that is mutually agreeable. At first glance, the proposed policy appears to allow either, and to call on EPA officials to make a judgement call in each case as to which is appropriate. I support this flexibility, though I hope that collaboration  becomes a common practice and not merely an allowable deviation from the norm.

As to the completeness of the goals, I would add a note. The draft states that timely and substantive public participation may extend the time needed to reach a decision, but pays off in reducing the time and expense related to subsequent challenges to the decision. In transportation and land use planning situations, good PIPs sometimes dramatically _reduce_ the cost and time needed to reach decisions, as well as preventing subsequent challenges. Is this not also true for EPA policy-making? Perhaps the PIP can include a goal of improving the efficiency of decision-making by constructively engaging all stakeholder groups from the outset.